Commentary on the Draft Scope for the Generic Environmental
Impact Statement for the World Trade Center Site

The latest document presented for comment in the process of rebuilding
the destroyed World Trade Center presents an interesting turn of
events.

I note that the Draft Scope does not bear the imprimatur of the Port
Authority,though it concerns the construction of Port Authority-owned
buildings on Port Authority-owned land...the development corporation
is not likely to have to deal with the lasting consequences of its
actions the way the property owners are.

It is gratifying that at long last a "Pre-September 11 Scenario"
and "Restoration Alternative" are being explicitly recognized as
benchmarks for the GEIS,after a prolonged process in which such
strategies for redevelopment have been implacably opposed despite
broad public support.However,given the history of official prejudice
against redevelopment based on restoration of what was destroyed,
there is a clear and substantial risk that the GEIS will seek to
portray these scenarios unfairly,in a bid to justify the unreasonable
programmatic requirements that have led to designs such as the
Proposed Action.

Rather,it is time that the adverse environmental impacts of these
requirements be evaluated,and the environmental advantages of
discarding the Proposed Action in favor of redevelopment based
on updated reaffirmation of the design principles that produced
the original World Trade Center be acknowledged.

From the beginning of the design process there has been insistence
that no portion of either of the "footprints" of the Twin Towers be
reclaimed for the purposes to which and for which the murderered
thousands gave their lives.This is a contentious issue on which many have
strong feelings on both sides...but total surrender to one side of the
issue has been an unreasonable constraint from the beginning.

Another constraint has been the narrow-minded obsession with tearing
the site completely apart by the total restoration of Greenwich Street,
dividing the site into sections with widely different uses and making
a mockery of the very idea of an integrated site design.Slashing an
arterial thoroughfare through one of the largest open spaces in Lower
Manhattan,seeking to create a busy vehicular intersection where there
was a pedestrian plaza,is among the most environmentally retrograde
proposals possible for the project area.Yet this was demanded of all
designers seeking to propose site plans...though everyone who bothered
to comment when the Project for Public Spaces opened a message board
for commentary on reopening Greenwich Street opposed the idea.

And there was the recurring demand for "phased construction",
rather than the speculative boldness solely responsible for the
Twin Towers being renowned and beloved icons of size far beyond
the typical and prudent...with its result that the commercial space
had to be carved into enough separate buildings that none of them
could be of particularly imposing size,certainly not two.And with
a large number of buildings required on a site fragmented by streets
and with a substantial portion forbidden to development,crowding
was assured.

Together these three requirements form a prescription for disaster,
and the design by Studio Daniel Libeskind has amply fulfilled this
request.

The signature of this design,the largest block left after the
floodgates were opened to traffic passing through the Tobin Plaza
site day and night,is of course the gaping pit...widely referred
to as the "deathpit".This chilling effort to enshrine the handiwork
of ten terrorist murderers,exposing the crumbling slurry wall laid
bare by their horrific destruction,is a nightmare for numerous reasons.

The symbolism of such deference to the killers' intent,the open
inspiration to future terror attacks offered by the assurance of
their leaving a lasting legacy,can be left aside in this commentary
as it concerns the environmental drawbacks.But we can not forget
that Daniel Libeskind stated explicitly that the attacks would be
"taken as guidance".

This pit is exposed to the weather cycles,which the slurry wall
was never meant to be.Snowdrifts will pile up with no means to plow
them out,rain will accumulate,frost will form on exposed surfaces.
Maintenance will be both necessary and difficult,year by year,
in the shadowy depths of this depression.

Should the exposed wall,built with the intent of the weight of the
World Trade Center complex being there to hold it and push it west
against the encroaching river channel even before the World Financial
Center was built with the potential to push it east,not be maintained
assiduously enough,there is the risk of collapse.Slight seepage has
already been noticed in the few years the wall has been exposed,and
the partial reburial of the wall will not be enough to eliminate this
risk.

Heavier-than-air pollutants will settle from the surrounding streets
into the confines of the pit,the exhausts of passing motorists
silently sinking into the memorial section.The unique size and depth
of this sector may make it a singular magnet for noxious fumes.

The depression below ground level has been defended as offering
respite from the noise of the surrounding streets...but it can not
reclaim the refuge that was offered by not having Fulton and Greenwich
Streets run through the site in the first place.Simply leaving the
site whole is both safer and more sensible.

The obstacle the pit presents to those seeking to cross the site
from east to west and back has been highlighted.Where in the old
WTC going between West and Church Streets required simply walking
through the side spaces between buildings,under the Proposed Action
it requires avoidance of the pit and a crossing of busy Greenwich
Street,envisioned as full of traffic meant to encourage acceleration
of the already rapid population growth of Downtown...another
environmentally retrograde vision of the unpopular incumbent Mayor.

The GEIS must not soft-pedal any of these hazards.

The issue has been raised of how to handle the traffic of visitors
to the memorial.It needs to be recognized that this traffic will
hit peaks early on that will not be revisited...those most interested
in seeing the memorial will see it as early as they can,and return
only rarely thereafter,while future generations will feel less and
less connection to the event.There is a long history of memorials
becoming backwaters with time,including within Manhattan.The recent
fall-off in interest after the death of Diana,Princess of Wales is
instructive...where in its first year the family memorial to her
sold all its tickets rapidly,today her memorial charity is being
urged to close its doors.The GEIS plans to examine conditions
anticipated in the years 2009 and 2015...it would be a mistake
to assume that,if the memorial is open by 2009,by 2015 the traffic
would not have declined permanently from the early level of interest.

For these and other reasons the "Restoration Alternative" must be
no empty "straw man" in the GEIS.It must be fleshed out,regardless
of official bias toward the proposed Action,sufficiently to demonstrate
its numerous advantages.

While it must necessarily be seen as a restoration of the 16 acres to
a large open space dominated by two gargantuan towers surrounded by
far lower structures,it is disingenuous to treat these new towers as
if they would be built with the technology of the 1960s with no form
of improvement.The Restoration Alternative against which the Proposed
Action must be measured must be one that would now be built,given a
mandate to rebuild in the spirit of what was destroyed.

The past 35 years of technology would unquestionably be employed
in constructing the new Twin Towers,improving their strength and
safety to levels never before seen,levels only made possible by
the buildings' breathtaking size offering sufficient income to make
them economical.

Environmental mitigation of adverse consequences of the former
Towers would be certain,and environmental hazards of the Proposed
Action would be avoided.The new Towers would be engineering marvels
of their own time as the originals were of theirs...Mr. Libeskind's
slant-topped wall of Church Street high-rises and his flimsy and
transparent "Freedom Tower" are more examples of abstract art,
and the entirely ornamental cagework proposed by David Childs
would eliminate the last vestiges of functionality for any space
above the 70th floor.

Of course a Restoration Alternative would not mean no memorial...the
attacks of 1993 led to the creation of a memorial,and the attacks of
2001 would be recognized as well.And a proportionate memorial would
be easily accomodated by the traffic capacity of a restored World
Trade Center,which was a tourist attraction on a scale both large
and stable over the long term,thanks to the distinctive characteristics
of the buildings.

Other voices will urge modification in other directions.
But it is important to understand the motives behind various interest
groups.Just as the small active cadre of those who seek to speak for
the families of those who were slaughtered represent not a cross-section
of such survivors,but a self-selecting sample of those both most
emotionally distressed by their loss and most determined that their
personal grief guide public policy,the "civic interest" groups like
New York New Visions,Imagine New York,and the Civic Alliance are not
representative of public opinion,but of established lobbies demanding
change in the city.The desire to treat the terror attacks as a handy
chance to implement wish-lists must be rejected.

Until September 11th 2001 the status quo had no established lobby
because it did not need to be defended...today a conspiracy of
bureaucracy seems determined to leave the status quo of before
September 11th 2001 defenseless.This environmental review process
must not be perverted into another stage of that conspiracy,but
must honestly weigh the drawbacks of failing to set ourselves back
onto the course we were on before thousands of valiant lives were
unconscionably snuffed out,and iconic structures revered the world
over collapsed into ruin.

Where ten murderers in hijacked airplanes set out to humble New
York's financial district never to rise again,timid beancounters
and utopian theoreticians must not be allowed to finish the job.

The GEIS must be a fair evaluation of the consequences of the choices
before us,not a biased attempt to sell an eyesore imposed in the teeth
of public disinterest and dislike.